One it is only a proposed rule, so it does not help anybody yet. But if DDTC ever implements this proposed change, it will have made a big step in the direction of making life easier for countries who deal with US defense articles. This proposal, if implemented, would, for example, eliminate the requirement that foreign (i.e., non-US) end-users and consignees on Technical Assistance Agreements and Manufacturing License Agreements first identify the nationalities of their dual national and third country national employees in the agreement application and thereafter limit access to US defense articles to only those nationalities approved on the application. Of course, all burdens eliminated by one hand must be replaced by burdens imposed by the other hand—we will look at the details of the proposal below. (more…)
Archive for the ‘Defense Trade Controls’ Category
DDTC Publishes Proposed Change for Employees of Non-US End-Users and Consignees
Tuesday, September 7th, 2010 by John BlackThe Check’s in the Mail (Export Control Reform [Again])
Wednesday, June 9th, 2010 by John BlackEditorial Analysis by John Black
I am old. I can’t even count the number of times I have heard well intentioned high level government officials tell us that they plan to make significant reforms in the US export control system. Some government officials have told me that they are going to make the system so transparent and user friendly that they will put consultants like me out of business.
It’s been 26 years for me in this business and numerous government pledges to make things better. As far as I can tell, I am still here and there is still a huge demand for assistance in dealing with the infinite number of problems that US export controls create for companies who try to comply with the rules. Yes, this reform could be different.
So, I apologize (for a change) in advance for being the cynic as a good number of my peers spout enthusiastically about Defense Secretary Gates’ call for comprehensive reform to the US export control system. Reform certainly makes sense. Comprehensive reform could both promote national security and make compliance a bit easier for companies.
Comprehensive reform is highly unlikely. Adjustments to certain aspects of US export controls might be the better-than-nothing result we should hope for. And, changes to the current system that will create a lot of extra work for us without actually improving anything is what we should fear. (Well, this last scenario will probably be a gold mine for my seminar and consulting businesses.) (more…)
DDTC List of Companies with Name Changes or Mergers
Friday, April 16th, 2010 by John BlackHere is a list of the companies for which the DDTC has announced name changes or mergers. Check this list to see if any of these parties are on licenses, agreements, or approval that you have now, have applied for, or are about to apply for. Click on the link to see the details.
- GE Fanuc Intelligent Platforms Technology Corporation to GE Intelligent Platforms Technology Corporation. (3.08.10) Click here to read.
- GE Fanuc Intelligent Platforms Embedded Systems, Inc. to GE Intelligent Platforms Embedded Systems, Inc. (3.08.10) Click here to read.
- GE Fanuc Intelligent Platforms (Colorado), Inc. to GE Intelligent Platforms (Colorado), Inc. (3.08.10) Click here to read.
- ITT Systems Division and ITT Federal Services International Corporation Changing to ITT Systems Corporation. (3.08.10) Click here to read.
- i-Logistics USA Corporation Changing to Itochu Logistics USA Corporation. (2.22.10)
Click here to read. - G4S Security Services (Canada) Ltd. to G4S Secure Solutions (Canada) Ltd. (2.22.10) Click here to read.
- GE Fanuc Intelligent Platforms of the U.S. Changing to GE Intelligent Platforms. (2.22.10) Click here to read.
- GE Fanuc Intelligent Platforms (Bracknell) Limited of the United Kingdom Changing to GE Intelligent Platforms (Bracknell) Limited (2.22.10) Click here to read.
- GE Fanuc Intelligent Platforms Limited of the United Kingdom Changing to GE Intelligent Platforms Limited. (2.22.10) Click here to read.
- Sartomer Company, Inc. Changing to Cray Valley USA, LLC. (2.22.10) Click here to read.
- Saab AB (publ) Entities Name Changes. (2.16.10) Click here to read.
- Saab Technologies, Inc. to Saab North America, Inc. (2.12.10) Click here to read.
And the Wind Cries MARY 1.0 for D-TRADE Status
Friday, April 16th, 2010 by John BlackDDTC announced that the full implementation of the MARY Status Retrieval System is available now. Mary 1.0 replaces the lighter precursor version MARY “lite” released in November.
MARY is accessible from the new DTAS Online Portal page: https://dtas-online.pmddtc.state.gov
Users can also link directly to MARY at https://mary.dtas-online.pmddtc.state.gov/
For more information: http://www.pmddtc.state.gov/documents/Industry%20Notice_20100305.pdf
State/DDTC Requires Eight Copies for CJs
Friday, April 16th, 2010 by John BlackIf you are going to submit a Commodity Jurisdiction (CJ) determination request, DDTC says you must mail it in (FedEx, DHL, UPS, USPS) and you must include 8 complete copies of a fully executed DS-4076 CJ and all supporting documentation.
DDTC Announces Policy for Goodrich Acquisition of AIS Global Holdings
Friday, February 19th, 2010 by Danielle McClellanGoodrich Corporation recently acquired AIS Global Holdings LLC and its subsidiaries Atlantic Inertial Systems Inc. of the US and Atlantic Inertial Systems Limited of the UK. There will be no name changes due to the acquisition and DDTC has determined that all approved authorizations will not require an amendment to reflect this acquisition. BUT…any US applicants with DDTC authorizations which identify Atlantic Inertial Systems Inc. or Atlantic Inertial Systems Limited must maintain a copy of the web notice with the authorization file.
Web Notice: http://pmddtc.state.gov/licensing/documents/WebNotice_Goodrich-AIS.pdf
